NEWSLETTER-2017

165 ARBITRATION LAW Conclusion When the law applicable to the arbitration agreement is not spe- cifically determined by the parties, there are several approaches for the courts and arbitral tribunals to reach a decision. However, the most strongly supported point of view is application of the law of the seat of arbitration to the arbitration agreement. On the other hand, the common approach adopted in French practice is likely to become widespread. Award no. 8910, Collection IV, p. 569-579; ICCAward no. 4131, IXYBCA 1982, p. 131 et seq.; ICC Award no. 5065, Collection II, p. 330 et seq.; ICC Award no. 8910, Collection IV, p. 569-579; ICC Award no. 5721, Collection II, p. 404.